WASHINGTON – Insiders say wagons are circling over the new methodology for
predicting TV station coverage and interference. The Federal Communications
Commission this week quietly released a revised version of the
methodology—OET-69—in a Mac-based software package dubbed “TVStudy.” It will
stand as the coverage analysis model for repacking TV stations after the
planned June 2014 incentive auction.

The National Association of Broadcasters had not publically responded to the
revision at press time, but a memo sent to members of the technology committee
urged them to “take a close look at the proposals and its implications on the
on-going incentive auction proceeding,” and “to refrain from publicly
commenting on its merit until we fully understand the implications of the FCC
action.”

One broadcast source said the revision had nothing to do with repacking TV
stations after the incentive auction. However, FCC Commissioner Mignon Clyburn
said updating OET-69 was critical to the repacking process.

“An important component of the
proposed incentive auction is the repacking of broadcast TV stations, including
the potential reassignment of stations to new operating channels. In order to
preserve the integrity of the broadcast TV service on which the American
consumers rely, we must get this process right,” she said in a statement. “As
the TVStudy Public Notice points out, the software that the commission staff
currently uses to implement OET-69 is based on source code and data from the
1990s and earlier. It is critical that the repacking process incorporates the
most updated and accurate data possible.”

A veteran broadcast engineer concurred, referring to the OET-69 revision as a
“very big piece” of the repacking methodology, but not the complete package.

“It only tells you how you’re going to analyze a given station, but not the
interrelated pieces of that,” he said. “It’s not to be underrated… it’s a big
piece of it. It’s the analysis model.”

The full repacking model will have to include a start point, he said.

“Where do you start and spread out from in your modeling,” he asked
rhetorically. “If you start in New York City, based on this new iteration, and
you begin packing stations, you would end up with a potentially different set
of criteria if you started out in Philly or Washington. It’s the interaction on
adjacent markets—they’re iterative.”

TV stations themselves participated in the last repacking triggered by the 2009
digital transition. During that process, the amount of spectrum TV stations
would occupy was a known known. What will be left after the 2014 incentive
auction is an known unknown.

There are other holes in OET-69 that are not yet plugged, like evaluating
coverage using an assumption that 50 percent of locations have reception 90
percent of the time, he said. The ratio is a relic of analog broadcasting.

“In digital, either you have a picture or you don’t,” he said.

The legislation authorizing the incentive auctions refers to OET-69 with regard
to preserving TV signal coverage area in the post-incentive auction
environment:

“In making any reassignments or
reallocations under paragraph (1)(B), the commission shall make all reasonable
efforts to preserve, as of the date of the enactment of this Act, the coverage
area and population served of each broadcast television licensee, as determined
using the methodology described in OET Bulletin 69 of the Office of Engineering
and Technology of the commission.”

The clause brings into question the legality of changing OET-69 before
the incentive auction, something the NAB suggested in a statement it shared
upon request:

“We are extremely concerned about the Public Notice. This proposal
introduces a new level of legal uncertainty as well as confusion about
coverage areas and populations served by local television stations. We’ll be
engaged with the commission, Congress and other stakeholders to ensure that
this proposal doesn’t distract or unnecessarily delay the task at hand.”

~ Deborah D. McAdamsSee “FCC
Reveals TV Channel Repacking Methodology”The FCC has quietly
revealed what amounts to its methodology for repacking TV channels in the
post-incentive auction spectrum band. The agency released a new version OET-69
software that it intends to use for the repacking, and is seeking input on its
efficacy.